Franciscan manzanita: The confiscation of public land

Update:  US Fish & Wildlife published the final rule designating critical habitat for Franciscan manzanita on December 20, 2013.  230.2 acres of land in San Francisco have been designated as critical habitat:  46.6 acres of federal land, 172.8 acres of parks owned by San Francisco’s Recreation and Parks Department, and 10.8 acres of private land.  The complete document is available here.  The document responds to public comments and explains any differences between the proposed designation and the final rule.  It makes interesting reading. 

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On September 5, 2012, US Fish & Wildlife (USFWS) announced that Franciscan manzanita is now an endangered species.  In 2009 the single plant known to exist in the wild was discovered during the reconstruction of Doyle Drive.  It was transplanted to an undisclosed location in the Presidio in San Francisco.

In addition to the conferral of endangered status, US Fish & Wildlife has designated 318 acres of  land in San Francisco as critical habitat for the Franciscan manzanita.   Critical habitats are places where the endangered plant is either known to have existed in the past or they are places that provide what the plant needs to survive.

Five of the eleven places in San Francisco designated as critical habitat are on federal land in the Presidio.  (Details about all the critical habitats are available here.)  Forty of the 318 acres are on private land.  Six of the critical habitats are in 196 acres of San Francisco’s city parks:

  • Corona Heights
  • Twin Peaks
  • Mount Davidson
  • Glen Canyon Park (erroneously called Diamond Heights by US Fish & Wildlife)
  • Bernal Hill Park (erroneously called Bernal Heights by US Fish & Wildlife)
  • Bayview Hill Park

The taxonomy of manzanita is ambiguous

There are 96 species of manzanita in California (1).  The ranges of most of these species are extremely small because the manzanita hybridizes freely and therefore adaptive radiation has resulted in a multitude of species, sub-species, and varieties that are adapted to micro-climates.  Many of these species are locally rare, which is consistent with the fact that 6 species of manzanita have already been designated as endangered, two of which are limited to the San Francisco peninsula:  Raven’s manzanita and Franciscan manzanita.

The genetic relationship between these two species of manzanita is ambiguous, which is reflected in the constantly shifting opinions of biologists about the taxonomy (species classification) of manzanita.  The 2003 Recovery Plan for Raven’s manzanita recounted the long history of these shifting views.  For some time, Raven’s and Franciscan manzanitas were considered the same species.  Then, for an equally long time, they were considered sub-species of the same species, Arctostaphylos hookeri.  It was not until 2007, that Raven’s was reclassified as a sub-species of Arctostaphylos montana.  Presently, Franciscan manzanita is classified as its own species, Arctostaphylos franciscana. 

Clearly, this history of the biological opinion regarding these two species of manzanitas suggests they are closely related and morphologically (AKA anatomically) similar.  The Recovery Plan concludes, “The idea of ‘pure’ species in Arctostaphylos, with its many poorly defined taxa and prevalent hybridization has often been difficult to apply over the history of taxonomic work in the genus.”

To add to the confusion regarding the provenance of Franciscan manzanita, some biologists are of the opinion that the individual plant that was discovered on Doyle Drive is actually a hybrid, not a pure-bred Franciscan manzanita.  The East Bay Regional Park District botanical garden in Tilden Park has planted a clone of the individual plant from Doyle Drive.  It is labeled as a hybrid of Arctostaphylos uva-ursi, which is one of the few species of manzanita with a wide range.

This is the label on the “Doyle Drive” manzanita in Tilden Park Botanical Garden, indicating that it is a hybrid.

The park ranger who led us to this plant in the Tilden garden, pointed out that the plant is morphologically distinct from the Franciscan manzanita that has been resident in that garden for about 50 years.  He expressed his opinion that the Doyle Drive manzanita was properly labeled as a hybrid.

In what sense is the Franciscan manzanita “endangered?”

Franciscan manzanita has been available for purchase in nurseries for about 50 years.  It has been propagated by taking cuttings and therefore they are presumed to be genetically identical clones.  However, given that this plant has been sold to the public for a long time, we have no way of knowing exactly where they have been planted or if some have successfully reproduced by germinating seeds.  For all we know, this plant is thriving somewhere, perhaps even in a place we might call “wild.”  Perhaps the plant found on Doyle Drive was purchased in a nursery!

The individual plant found on Doyle Drive has been defined by USFWS as Franciscan manzanita despite the fact that some biologists consider it a hybrid of another species.  We understand that the motivation for designating this individual as an endangered species and providing it with critical habitat is based on an assumption that it is genetically different from the Franciscan manzanita that can be purchased in nurseries and that the chances of survival of the species may be improved by cross-fertilization of these two plants such that greater genetic diversity results from their union.

Yet we are offered no evidence of the genetic composition of the Doyle Drive individual or Franciscan manzanita sold in nurseries.  Nor are we provided any evidence that the Doyle Drive individual is even a genetically “pure” Franciscan manzanita rather than a hybrid of another species altogether.

If we weren’t being asked to devote 318 acres of land to the propagation of a plant with such ambiguous taxonomy, we might not question how little information we have been provided.  The technology of mapping the genome of this plant is available to us.  Why aren’t we making use of this technology to resolve these ambiguities?  The cost of planting 318 acres with this endangered plant far exceeds the cost of such genetic analysis.

We aren’t told what it will cost to plant 318 acres with this endangered plant, but we know that the cost of the recovery plan for Raven’s manzanita and lessingia was estimated as $23,432,500 in 2003.  Presumably that is an indication that the proposal for Franciscan manzanita will be a multi-million dollar effort.  The cost of transplanting the single plant from Doyle Drive to the Presidio was reported as over $200,000. (1)

Thirty years of endangered status for Raven’s manzanita has not saved this plant

We have already made the point that Raven’s and Franciscan manzanitas are closely related.  In its proposal for the designation of critical habitat for Franciscan, USFWS confirms this close relationship by referring us to the Recovery Plan for Raven’s.  In other words, the characteristics and horticultural requirements of these two species are so similar that a separate Recovery Plan for Franciscan is not necessary.  The Recovery Plan for Raven’s is applicable to Franciscan.

Therefore, we should assume that the fate of the recovery effort for Franciscan will be similar to that for the Raven’s.  Raven’s was designated as endangered in 1979.  Its first recovery plan was published in 1984 and the second in 2003.  Many 5-year reviews of its endangered status have been done during this 33 year period.  The most recent 5-year review was published in June 2012; that is, very recently.

So what does USFWS have to show for 33 years of effort to save Raven’s manzanita from extinction?  Almost nothing:

  • Clones of the single plant in the wild exist in several botanical gardens.  These clones are genetically identical and their growth in maintained gardens does not meet ESA standards for recovery.
  • “The wild plant has been observed to set seed although no natural seedling establishment is known to have occurred.” (6)
  • The plant has been the victim of twig blight several times, but the fungus cannot be treated because it would damage the mycorrhizal fungi in the soil upon which the plant is dependent.
  • The seeds depend upon animal predators for dispersal which are largely absent in an urban area.
  • The pollinators of manzanita have not been identified and therefore there is no assurance that they still exist in this location.
  • The 5-year review concludes that:  “…recovery sufficient to warrant full delisting is not projected in the foreseeable future for [Raven’s manzanita] and may not be possible.”

We can’t appreciate the significance of the utter failure of this effort without some mention of the extreme methods used to overcome these obstacles.

The seed of manzanita is germinated by fire.  However, the exact relationship between fire and germination is not known.  Therefore, many complex experiments have been conducted on the few viable seeds produced by the Raven’s manzanita in a futile effort to determine the winning combination.  These experiments are described in detail in an article in Fremontia (1).  In short, various combinations of fire, heat, cold, smoke, liquid smoke, etc., were tried and failed to determine exactly what triggers germination of manzanita seeds.

We should remind our readers of the legal definition of “recovery” according to the Endangered Species Act.  According to the 5-year review for Raven’s manzanita, here are two of the criteria for recovery toward which there has been no progress in 33 years:

  • “At least five spontaneously reproducing variable populations are established in reserves…in San Francisco…”
  • “At least two sexually reproduced generations are established within the Presidio.”

Frankly, it is no longer credible to expect the recovery of Raven’s manzanita and this failure implies the same fate for Franciscan manzanita.

Can the public parks of San Francisco meet the horticultural requirements of Franciscan manzanita?

The public parks of the City of San Francisco cannot meet the horticultural requirements of the Franciscan manzanita because it requires fire to germinate its seeds. 

All of the critical habitats proposed by USFWS in San Francisco’s public parks are designated “natural areas.”  According to the DRAFT Environmental Impact Report of the “Significant Natural Resource Areas Management Plan,” prescribed burns are prohibited in the natural areas.  Therefore, unless there are unplanned wildfires in the six public parks proposed as critical habitat, it will not be physically possible to “spontaneously reproduce” this plant, as required by the Endangered Species Act. 

Granted, the City of San Francisco could revise its management plan for the natural areas to allow—or even require—prescribed burns in the six parks proposed as critical habitat.  In that case, the citizens of San Francisco would be subjected to air pollution and risk of causing an uncontrolled wildfire in surrounding residential communities.  The Natural Areas Program would be subject to even more criticism than it already endures.

The Natural Areas Program is extremely controversial in the City of San Francisco because it destroys healthy non-native trees, it sprays pesticides on non-native vegetation in public areas, it destroys the habitat of wildlife, and it limits the public’s recreational access to trails which are often fenced.  Subjecting the natural areas to prescribed burns is surely the bridge too far for the public which would jeopardize the future of the entire program.  Why would the City of San Francisco be willing to push the public over the edge by requiring prescribed burns in six urban parks in densely populated residential communities?

Furthermore, some of the proposed critical habitat is in heavily forested areas, which are not compatible with the requirement of manzanita for full sun.  As they were on behalf of Raven’s manzanita, these trees would be destroyed.  The City of San Francisco is already planning to destroy 18,500 trees over 15 feet tall to accommodate its desire to reintroduce native plants to forested areas. (3)  How many more trees would need to be destroyed to accommodate Franciscan manzanita?  How much more carbon dioxide would be released into the atmosphere by the destroyed trees?

Bayview Hill is one of the proposed critical habitats which are heavily forested.  According to SNRAMP (3), 17.16 acres of Bayview Hill is forested.  Given that Bayview Hill is the only proposed critical habitat which is outside the known historic range of Franciscan manzanita, the loss of 17 acres of trees does not seem a fair trade for a plant with few prospects for survival.

The proposed critical habitat in Glen Canyon Park (inaccurately called Diamond Heights by the proposal) is also forested in a portion of the 34 proposed acres of critical habitat.  This is a park in which the destruction of trees is being hotly contested.  The community in this park does not need the additional controversy of tree destruction for the sole purpose of planting an endangered species.

Proposed critical habitat in other city parks is likely to be controversial for other reasons, primarily because additional restrictions on recreational access will undoubtedly be required to protect this endangered plant.  Bernal Hill is an example of a city park with a huge community of visitors who will undoubtedly be enraged by further loss of recreational access.  They have already been squeezed by the restrictions imposed by the Natural Areas Program.

This proposal for critical habitat is not good public relations for the Endangered Species Act

The City of San Francisco is the second most densely populated city in the country.  It is comprised of only 29,888 acres.   There are only 3,317 acres of City-managed parks in the city. (2) The proposed critical habitat in City-managed parks is 196 acres, 6% of total City-managed park land in San Francisco.

Please ask yourself these questions:

  • Does it make sense for 6% of all City-managed park land to be permanently committed to planting an endangered plant which can be purchased in nurseries?
  • Does it make sense to confiscate 6% of all public parks for a plant the identity of which we are not certain?
  • Does it make sense to throw the public out of 6% of all public parks on behalf of a plant that will never be able to spontaneously reproduce unless there is an accidental wildfire?

We think the answers to these questions are no, no, and no.  This is an ill-advised proposal which makes a mockery of the Endangered Species Act.  This is an important law that is trivialized by a proposal that will be physically impossible to implement without endangering the public and damaging the environment. 

Comments on the proposed critical habitats will be accepted until November 5, 2012. Comments may be submitted online at the Federal eRulemaking Portal at http://www.regulations.gov (Docket Number FWS–R8–ES–2012–0067) or by U.S. mail to:

Public Comments Processing
Attn:  FWS–R8–ES–2012–0067
Division of Policy and Directives Management
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive, MS 2042-PDM
Arlington, VA 22203.

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Bibliography

(1)      Gluesenkamp, Michael, et al., “Back from the Brink:  A Second Chance at Discovery and Conservation of the Franciscan Manzanita,” Fremontia, V37:4/38:1, 2009-2010

(2)      Harnik, Peter, Inside City Parks, Trust for Public Land, 2000

(3)      San Francisco Recreation and Park Department, “Significant Natural Research Area Management Plan (SNRAMP),” 2006

(4)      San Francisco Recreation and Park Department, “DRAFT Environmental Impact Report for SNRAMP,” 2011

(5)      USFWS, “Designation of Critical Habitat for Franciscan Manzanita,” September 5, 2012

(6)      USFWS, “5-Year Review of Endangered Status of Raven’s Manzanita,” June 2012

(7)      USFWS, “Recovery Plan for Coastal Plants of the Northern San Francisco Peninsula,” 2003

Open Letter to the Sierra Club

In this post we are writing an open letter to the Sierra Club about an article in their recent edition of the Yodeler, the newsletter of the Bay Area Chapter of the Club.  The article is available here

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Dear Sierra Club,

We are writing about an article in the Yodeler about the “Wildfire Hazard Reduction and Resource Management Plan” of the East Bay Regional Park District.  A charitable description of that article is that it is misleading and inaccurate.

The most important flaw in the article is that it omits the most controversial issue in the “Wildfire Plan.”  It describes the methods used to eradicate non-native plants and trees as follows:  “Methods for removal include hand removal, grazing by cattle and goats, and limited controlled burns.”

In fact, herbicides are often used by EBRPD to kill non-native plants and trees.  The failure to mention this use of herbicides in the Yodeler cannot be dismissed as ignorance of this fact since it is described in detail in the “Wildfire Plan” and was the most frequently mentioned issue in the meeting of the EBRPD Board of Directors at which the Plan was approved.  The Sierra Club was represented at this meeting and surely noticed that many speakers expressed their concern regarding the use of herbicides officially designated “hazardous chemicals” by OSHA.  The toxicity of these herbicides is reported  here and here.

The description of controlled burns required by the Plan as “limited” is debatable.  We believe that the use of controlled burns for the sole purpose of restoring native plants is dangerously irresponsible.

At the recent meeting of the Executive Committee of the Board of Directors of the EBRPD, the “fuel management” plans for 2011 were presented and approved.  These plans included prescribed burns in 5 locations, on approximately 250 acres.  These burns were described by the Assistant Fire Chief as unrelated to reduction of fuel loads, but rather for the purpose of supporting restoration of native plants to the parks.  A representative of the California Native Plant Society expressed  gratitude to East Bay Regional Park District  for conducting these burns for the benefit of native plants.

We object to the use of controlled burns for this purpose because such burns have a history of causing major wildfires (reported here).  Some of these controlled burns will occur in areas with many acres of eucalyptus and Monterey pine that both the Sierra Club and the East Bay Regional Park District claim are highly flammable.  The burns are scheduled to occur during the height of the fire season.  Such burns also reduce air quality and release carbon and particulates into the air.

It baffles us that the Sierra Club endorses the use of dangerous herbicides and prescribed fires.  However, we aren’t surprised because the Club’s comments on the Draft EIR for the “Wildfire Plan” warned us that the Sierra Club considers the restoration of native plants a higher priority than the public’s safety.  The lawyer representing the Club said on behalf of the Club, “Perhaps the most serious problem with the Plan is that it explicitly makes the preservation and enhancement of wildlife a secondary concern, with minimizing fire danger the primary concern” and concluded, “However, the over-emphasis on decreasing wildfire risks at the expense of habitat values is disturbing.”

The Club’s priorities reveal a misanthropic agenda that betrays its original ideals and its commitment to the environment on behalf of all living creatures, including humans.

Million Trees

(UN)controlled Burns

Today’s SF Chronicle reports that yet another “controlled” (AKA “prescribed”) burn is responsible for a wildfire in California.  This fire in the Santa Cruz Mountains burned 485 acres in October 2009, injuring 4 of the 1,700 firefighters who fought it at a cost of $4 million.  That cost doesn’t include the claims for damages of the property owners who lost their homes.

This isn’t the only controlled burn that has caused major wildfires in California and elsewhere.  For historical perspective, let’s start with the Bandelier Monument Fire in New Mexico.  This fire, began in May 2000 as a prescribed burn and eventually burned over 45,000 acres, threatened the Los Alamos National Laboratory and destroyed 235 structures.  The Department of the Interior suspended all prescribed burns while an inquiry was conducted and policy was revised to theoretically prevent similar accidents.

Did revision of policy stop so-called controlled burns from causing wildfires in our national parks?  No, it did not.  In October 2009, the Big Meadow Fire in Yosemite began as a prescribed burn and eventually burned 7,425 acres.  NPS apparently hadn’t learned much from their bad experience 9 years earlier at the Bandelier Monument.

Yosemite Big Meadow Fire, NPS photo

The National Park Service isn’t the only manager of public land that has had bad luck with controlled burns.  In 2003, the California State Park Department was responsible for starting a fire on San Bruno Mountain in South San Francisco intended to burn 6 acres that eventually burned 72 acres and came perilously close to homes, according to the SF Chronicle.

We should not be surprised by the unpredictable results of prescribed burns.  Fire scientists at UC Berkeley conducted a series of experimental prescribed burns in chaparral in Northern California, hoping to arrive at a model of fire behavior that would improve the predictability of such burns.  They arrived at the conclusion that “…it is extremely difficult to predict with certainty where the fire will spread…For more than half of the transects installed, the flaming front did not traverse the transects as predicted…” (1)

You might ask, “If these prescribed burns keep causing major wildfires, why do we continue starting them?”  Good question, and we are going to answer that.  The conventional wisdom is that because fires have been suppressed in the past century or so, fuel has built up that has become extremely dangerous.  Theoretically, we must restore the “natural” fire cycle to prevent this dangerous build up of fuel that will inevitably cause a huge wildfire if we don’t reduce the fuel load with smaller (hopefully) fires.  Sounds like a good argument, but is it true?  Some scientists say it isn’t.

Jon E. Keeley, Ph.D. (Biologist, US Geological Service) says in “Fire Management in the California Shrublands,”

“Fire management of California shrublands has been heavily influenced by policies designed for coniferous forests, however, fire suppression has not effectively excluded fire from chaparral and coastal sage scrub landscapes and catastrophic wildfires are not the result of unnatural fuel accumulation. There is no evidence that prescribed burning in these shrublands provides any resource benefit and in some areas may negatively impact shrublands by increasing fire frequency. Therefore, fire hazard reduction is the primary justification for prescription burning, but it is doubtful that rotational burning to create landscape age mosaics is a cost effective method of controlling catastrophic wildfires.”

Obviously, there isn’t scientific consensus that prescribed burns reduce fire hazard, so perhaps there is another reason why we pursue this dangerous course.  Yes, there is, and once again we turn to the native plant movement to explain why we are harming our environment and posing unnecessary dangers to animals, including humans.

The scientific literature is rampant with evidence that periodic fire is essential to the health of native plants.  Here is an example from a renowned academic book about California’s ecology that has the status of a standard textbook:

“The [chaparral] community has evolved over millions of years in association with fires, and in fact requires fire for proper health and vigor.  Thus it is not surprising that most chaparral plants exhibit adaptations enabling them to recover after a burn.  Many species are sprouters; the aboveground parts may be killed, but new growth arises from roots or buds at the base of the stem…Other species have seeds that require fire in order to break dormancy; they will not germinate unless they have been heated.  The cones of some chaparral conifers open only after they have been heated.  Some herbaceous species will not germinate unless there is ash on the ground when it rains…In the absence of fire, a mature chaparral stand may become senile, in which case growth and reproduction are reduced.”  (Schoenherr, A Natural History of California, 1992, UC Press)

This is also an opportunity to show how the native plant agenda has been adopted by local managers of our public lands. The “Wildfire Hazard Reduction and Resource Management Plan” of the East Bay Regional Park District announces its intention to conduct prescribe burns for the following purposes:

  • “Grassland and Herbaceous Vegetation…broadcast burns in the summer or early fall [fire season] are known to favor native plants.” (page 128)
  • “Maritime Chaparral…This [native] vegetation type and the Manzanita it supports are also fire dependent. Without disturbance by fire the Manzanita does not reproduce, becomes decadent, and is replaced by shade tolerant species.” (page 132)
  • “North Coastal Scrub…This plant community [of native plants] is adapted to natural fire cycles, and most species found within this plant community resprout easily to rejuvenate individual specimens after fire, or require fire to trigger germination.”  (page 139)
  • “[Native] Coyote Brush Scrub…is adapted to natural fire cycles.  Most species resprout easily to rejuvenate individual specimens after fire, or requires fire to trigger germination.” (page 149)

Are any of these purposes related to reducing fire hazard?  You be the judge.

The management plan of San Francisco’s Natural Areas Program also announces its intention to use prescribed burns in the Initial Study (the first stage of environmental review under CEQA) of the program, but offers no information about the effect of these burns on the environment.  In a city such as San Francisco, in which there is no history of wildfire, we must assume that the sole purpose of these burns will be to benefit native plants.

Clearly controlled burns frequently cause major wildfires.  Fires, whether intentional or not, also release harmful particulates into the air and reduce air quality.  There is no evidence that controlled burns prevent wildfires.  Yet, there is considerable evidence that they benefit native plants.  We conclude that the primary purpose of controlled burns is to benefit native plants. 

 


(1) Scott Stephens, et. al., “Measuring the rate of spread of chaparral prescribed fires in Northern California,” Fire Ecology, Vol. 4, No. 1, 2008